Privacy Policy

This Privacy Policy describes how FEVO Global Ltd (“FEVO”, “we”, "our” or “us”) collects, uses, and discloses your personal data as a controller when:

(1) you interact and use www.fevo.com, www.offer.fevo.com, www.myfevo.com, and any other digital platform where this Privacy Policy appears (the “Sites”);

(2) you interact and use our services, features, content, or applications (collectively with the Sites, the “Services”);

(3) you communicate with us in any way; and

(4) we interact with certain third-party providers and organizations (“Third Parties”). Please note, this Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications that you access through the Services, including websites of third parties offering goods, services, events, or other offerings utilizing the FEVO infrastructure (“Offer Provider”). The Offer Providers are controllers of your personal data and FEVO processes that personal data on the instructions of the Offer Providers as a processor.

While we attempt to facilitate access only to those third-party services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those third-party services. We encourage you to carefully review the privacy policies of any third-party services you access.

ACKNOWLEDGMENT

BY ACCESSING AND/OR USING OUR SERVICES, AND/OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY.

WHAT INFORMATION DOES FEVO COLLECT?

The information we gather enables us to (amongst other things) personalize, improve, and operate the Services. In connection with certain aspects of the Services, we may request, collect, use and/or display to you some of your information, including:

ACCOUNT AND PURCHASE INFORMATION

When you create an account for our Services, including third-party websites or applications, such as Offer Provider websites or applications, you will provide information such as your name, email address, phone number, address, payment information, and/or password. We may also ask for information relevant to the offer, event, or prizes that the Offer Provider may provide. Please note, when you provide us with your email address and/or telephone number, we will be creating an account on your behalf to identify and catalog your purchases through FEVO. However, as stated above, where this is provided in connection with an Offer Provider website or application, we will process this on the instructions of the Offer Provider as a processor.

YOUR COMMUNICATIONS WITH US

We collect information from you such as email address, phone number, or mailing address when you request information about our Services, register for our marketing communications or loyalty program, request customer or technical support or otherwise communicate with us.

ANALYTICAL DATA

We may process analytical data about your use of our Sites ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. The source of the usage data is Google Analytics and HEAP. This usage data may be processed for the purposes of analyzing the use of the Sites and Services.

SURVEYS

We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information.

SOCIAL MEDIA CONTENT

We may offer forums, blogs, or social media pages. Any content you provide on these channels will be visible to the public.

SWEEPSTAKES OR CONTESTS

We may run sweepstakes and contests. Contact information you provide, may be used to contact you about future promotional and marketing purposes, if permitted by law. In line with local law, we may be required to publicly share the information of winners with Third Parties.

USER CONTENT

Some features of the Services may allow you to provide content to the Services. This includes content you provide on your profile, and information about what events you have or will attend. We may disclose such content to Third Parties in a manner that does not reveal your identity, where appropriate.

LOCATION INFORMATION

Some of our Services may include features based on your actual location and may report your current location (“Location-Based Services”). To the extent you use any Location-Based Services, we will collect and store information about your location at the time you use those Location-Based Services.

This information can come from a variety of sources you use to access the Services; for example, a mobile phone may report its GPS location or IP address at the time Location-Based Services are used.

You can opt out of Located-Based Services by changing the settings directly on your device.

You can opt in to Location-Based Services through the Cookie Notice on our website.

You can find more information about how Cookies are used in our Cookie Policy (https://fevo.com/cookie-policy)

FINANCIAL INFORMATION

If you make purchases through the Services, your financial information, such as your payment method (valid credit card number, type, expiration date or other financial information), is collected and stored by our Third-Party payment processing company (the “Payment Processor") and use and storage of that information is governed by local laws and the Payment Processor's applicable terms of service and privacy policy. We currently use Stripe (www.stripe.com) and Checkout (www.checkout.com) as our Payment Processors. In order to facilitate your order transactions, we collect and store your billing postcode, credit card type and the last four digits of your credit card number, but no other financial information.

SHIPPING INFORMATION

We may collect your shipping information in connection with certain purchases through the Services. We may pass this information to our Payment Processor, Offer Providers, partners, and other Third Parties for purposes of customer service, fulfillment, shipping and returns. The use of your information by such parties is subject to their respective privacy policies and terms where applicable.

INFORMATION FROM OTHER SOURCES

If you access our Services through a Third-Party website or application, such as an Offer Provider, app store, a Third-Party login service, or a social networking site (such as Facebook), we may collect information about you from that Third Party. If you do not want us to receive your personal data from Third-Party sources, please communicate your preferences directly with the relevant Third-Party sources.

Information we collect through these services may include your name, user identification number, username, location, gender, birth date, email, profile picture, and contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

USE OF ANONYMOUS & AGGREGATE INFORMATION

We collect statistical information about how both unregistered and registered users use the Services. Some of this information is derived from your personal data. This statistical information is not identifiable to you. We do not attempt to re-identify it except to ensure our anonymization processes are in compliance with applicable data protection laws.

HOW WILL MY INFORMATION BE USED?

We use your personal data for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

  • Customer service-related activities including, managing your information and accounts
  • Providing access to certain areas, functionalities, and features of our Services
  • To process your online purchase and deliver the product to you
  • Communicating with you about your account, activities on our Services, comments and complaints, and policy changes
  • Undertaking activities to verify or maintain the quality or safety of a Service or device
  • Processing your financial information and other payment methods for products or Services purchased
  • Allowing you to participate in sweepstakes, prize draws and contests
  • Sharing personal data with Third Parties as detailed below
  • Enforcing our terms and policies

If you fail to provide the personal data required for us to fulfill our obligations under our contract with you, we may be unable to provide you with our Services.

With your consent:

  • Providing advertising, analytics, and marketing Services
  • Furnishing you with (tailored) materials/information about offers, promotions, products, and Services that may be of interest to you, including new content or Services and to send you surveys
  • Sharing personal data with Third Parties as detailed below
  • Other purposes you consent to, are notified of, and are disclosed when you provide personal data

Where we process your personal data based on your consent, you have the right to withdraw that consent at any time (i.e., opt out). Note, however, that your withdrawal of consent shall not affect the lawfulness of any processing we carried out, based on consent, before its withdrawal.

Providing, analyzing, and improving our Services, and managing our business, pursuant to our legitimate interest, such as:

  • Auditing relating to interactions, transactions, and other compliance activities to make sure that our e-commerce platform is managed in line with FEVO’s business processes for ISO27001, business continuity arrangements and ensuring quality control of our platform
  • Sharing personal data with Third Parties, including for the purposes identified below:some text
    • Improving, upgrading, or enhancing our Services or devices such as ‘point of sale’ or those of our Providers including by personalizing features, content, and recommendations
    • Furnishing you with (tailored) materials/information about offers, promotions, products, and Services that may be of interest to you, including new content or Services and to send you surveys where we are permitted to do so other than in reliance on your opt-in consent
    • Developing new products and Services
    • Debugging to identify and repair errors that impair existing intended functionality
  • In connection with a potential asset or stock acquisition, or the outsourcing or insourcing of services, providing reasonable diligence material to a Third Party, or meeting any disclosure obligations as required by law
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

Our legitimate interests are commercial in nature and include advertising, marketing, and promoting our products and Services, and our business. The legitimate interests of our partners are to sell tickets, merchandise and other items related to events that they stage.

You have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfill this request in all instances.

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Complying with our legal obligations, including:

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
  • Auditing relating to interactions, transactions, and other compliance activities to make sure that our e-commerce platform is managed in line with FEVO’s business processes for ISO27001, business continuity arrangements and ensuring quality control of our platform
  • Sharing or disclosing your personal information if we believe it is reasonably necessary to comply with a law, regulation, legal process, or governmental request
  • Verifying your identity and preventing fraud

If you fail to provide the personal data required for us to fulfill our legal obligations, we may be unable to provide you with our Services.

PROCESS INFORMATION ON BEHALF OF OUR OFFER PROVIDERS AS A PROCESSOR

Our Offer Providers may choose to use our Services to process certain data of their own, which may contain personal data. The data that we process through our Services is processed by us on behalf of our customer, and our privacy practices will be governed by the contracts that we have in place with our Offer Providers and their privacy policies.

If you have any questions or concerns about how such personal data is handled or would like to exercise your rights, you should contact the person or entity who has contracted with us to use the Service to process this personal data.

NOTICE REGARDING THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SOFTWARE DEVELOPMENT KITS

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs, forums, social media pages, and private messaging features. By using such Services, you assume the risk that the information provided by you may be viewed and used by Third Parties for any number of purposes and you should review these companies’ privacy policies in order to understand how they may use your information.

In addition, social media buttons such as Facebook (see below), ‘X’, Instagram, and LinkedIn (that might include widgets such as the “share this” button or other interactive mini programmes) may be used through our Services. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our site. Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

We may use Third-Party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal data for various purposes including to provide analytics services and content that is more relevant to you.

For more information in relation to third party websites, social media platforms and software development kits please read our Cookie Policy (https://fevo.com/cookie-policy). 

HOW, AND WITH WHOM, IS YOUR INFORMATION SHARED?

Certain of the Services are designed to help you share information with others. As a result, some of the personal data generated through the Services is shared publicly or with Third Parties.

SERVICE PROVIDERS

We may share any information we collect about you with our Third-Party service providers. The categories of service providers to whom we entrust your information include IT and related services; payment processors; customer service providers; and vendors to support the provision of the Services.

BUSINESS PARTNERS

We share your data with our business partners with whom we jointly offer products or services, including Third-Party websites and applications, such as Offer Providers. In such cases, our business partner’s name will appear along with ours.

AFFILIATES

We share your information with our affiliated companies.‍

ADVERTISING PARTNERS

We may allow Third-Party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day).

We may also combine and share such information and other information (such as past purchase history) with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit Third-Party websites within their networks. This practice is commonly referred to as ‘interest-based advertising’ or ‘online behavioural advertising’. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable, or otherwise of interest to you.

If you prefer not to share your information with Third-Party advertising partners, please ensure that you check your preferences.

More information can be found in our Cookie Policy (https://fevo.com/cookie-policy). 

OFFER PROVIDERS (WHERE WE ACT AS A PROCESSOR)

Offer Providers may choose to use our Services to process certain data of their own, which may contain personal data. Some of the data that we process through our Services is processed by us on behalf of the Offer Providers. In these circumstances, they will be the controller of your personal data, and their privacy policies will be applicable where we process personal data on their behalf.

If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity who has contracted with us to use the Service to process this data. They can be identified by checking who the event organizer is for the event you are attending.

DISCLOSURES TO PROTECT US OR OTHERS

We may access, preserve, and disclose any information we store associated with you to external parties if we, are required to: comply with law enforcement or national security requests and legal processes such as a court order; protect your, our or others’ rights, property, or safety; assist us in complying with our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

DISCLOSURE IN THE EVENT OF MERGER, SALE, OR OTHER ASSET TRANSFERS

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your personal data may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

INTERNATIONAL DATA TRANSFERS

Information we collect may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We take commercially reasonable steps to protect your personal information as it relates to any transfer that may take place.

Please contact us if you would like further details of the safeguards implemented including, a copy of the data transfer agreements.

WHAT ARE MY CHOICES?

You have certain choices about your personal data.

You can use some of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

ACCOUNT DEACTIVATION

Should you ever decide to deactivate your account, you may do so by emailing cpo@fevo.com. If you deactivate your account, any association between your account and information we store will no longer be accessible through your account. However, given the nature of sharing on the Services, any public activity on your account prior to deactivation will remain stored on our servers and will remain accessible to the public in accordance with applicable law.

HOW IS DATA RETAINED?

We store the information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

CALIFORNIA RESIDENTS

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The following disclosures and rights apply to you if your area California resident. All capitalized terms used in this section have the same meaning as those terms are defined under the California Consumer Privacy Act of2018 and its implementing regulations, as amended (“CCPA”):  

  • Notice of Financial Incentive. From time to time, we may offer a discount or Financial Incentive in exchange for you providing certain Personal Information o us, such as your contact information. Any discount we provide will be based upon our reasonable but sole determination of the estimated value of your Personal Information, taking into consideration, without limitation, estimates regarding anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law. By providing your information in response to any Financial Incentive, you are affirmatively opting-in to the discount program. If you wish to opt-out, do not submit your information. If you wish to withdraw your consent at any time, you may submit a request to cpo@fevo.com.
  • Notice of Collection. To learn more about the categories of Personal Information we have collected about California residents in the 12 months since this Privacy Policy was last updated, including the categories of sources from which we collected the information, the purposes for which we use the information, and the categories of third parties with whom we’ve shared the information, please see What Information Does FEVO Collect?, How Will My Information Be Used?, and How, And With Whom, Will Your Information Be Shared?
  • Notice of Disclosure for Business Purposes. To learn more about the categories of Personal Information we have disclosed about California residents for a Business Purpose to third parties in the 12 months since this Privacy Policy was last updated, including the categories of third parties with whom we’ve disclosed the information, please see What Information Does Fevo Collect?, and How, And With Whom, Will Your Information Be Shared?
  • Notice of Sale. We do not Sell the Personal Information of California residents in the traditional sense of the word. However, because the definition of Sell under the CCPA is broad enough to potentially include the sharing of your information with advertising and marketing partners, we provide California residents the right to opt-out of this type of sharing of their Personal Information. The categories of Personal Information we have shared with advertising and marketing partners in the 12 months before this Privacy Policy was last updated include direct identifiers, such as name, contact information, and IP address, as well as purchase history and interaction history with the Services. Much of this information is transmitted through certain Technologies. We do not knowingly Sell the Personal information of anyone 16 years or younger.
  • Right to Know. You have a right to ask that we disclose up to two times per year a list of: (1) the categories of Personal Information we’ve collected about you in 12 months prior to the date of your request; (2) the categories of sources from which we have collected that information; (3) the categories of Personal Information we have Sold, shared, or disclosed for a Business Purpose about you in the 12 months prior to the date of your request; (4) the categories of third parties with whom we have Sold, shared, or disclosed for a Business purpose your Personal Information; and (5) the specific pieces of your Personal Information. To submit such a request, please Contact Us.
  • Right to Delete.  You have a right to ask that we delete certain information we have about you, subject to certain exceptions such as to comply with a legal obligation, complete a transaction, or prevent against fraud or other unlawful activity. To submit a request to delete, please Contact Us.
  • Right to Opt-Out. You have a right to opt-out of the Sale of your Personal Information. As described above, we may share your Personal Information with advertising and marketing partners that could be considered a Sale of Personal Information under the CCPA. To opt-out of this sharing, please visit our Cookie Manager Tool and de-select the Advertising and Analytical cookies. To learn more, please visit Do Not Sell My Personal Information. If you have any questions about this right, please Contact Us.
  • Right to Anti-Discrimination. We will not discriminate against you in any way if you exercise any of the rights above.
  • Verification. In order to ensure we do not disclose your information to someone else, and to prevent an inadvertent deletion of your information based on a fraudulent request, we will verify your identity before responding to your request. To verify your identity, we will generally match the information you provide in your request with the information we have on file about you. Depending on the sensitivity of the information and request, we may request additional information from you, including a declaration signed under penalty of perjury.
CALIFORNIA MINORS

Persons under the age of 18 are not permitted to access or use our Services. If you are a California resident under the age of 18 and have nonetheless accessed and used our Services in violation of applicable laws and company policy, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information you have publicly posted on any of our Services. To make such a request, please send an email with a detailed description of the specific content or information to cpo@fevo.com with the subject line "CALIFORNIA MINOR CONTENT REMOVAL REQUEST." Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and there may be circumstances in which the law does not require or allow removal even if requested.

‍ACCESSIBILITY

This Privacy Policy uses industry-standard technologies and was developed to align with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

CHILDREN’S INFORMATION

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

WHAT HAPPENS WHEN THERE ARE CHANGES TO THIS PRIVACY POLICY?

We may amend this Privacy Policy from time to time. If we make material changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email.

CONTACT US

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to cpo@fevo.com. We will make every effort to resolve your concerns.

FEVO, Inc.
12 Little W. 12th Street
New York, NY 10014

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Policy last updated March 19, 2024.